COMMUNITY INVOLVEMENT PLAN
KOPPERS SUPERFUND SITE
EPA ID FLD980709356
GAINESVILLE, ALACHUA COUNTY, FLORIDA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
May 2011
REVISION
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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY'S
SUPERHJND COMMUNITY INVOLVEMENT PROGRAM is COMMITTED
TO PROMOTING COMMUNICATION BETWEEN CITIZENS AND THE AGENCY.
ACTIVE PUBLIC INVOLVEMENT is CRUCIAL TO THE SUCCESS OF ANY PUBLIC PROJECT.
EPA'S COMMUNITY INVOLVEMENT ACTIVITIES AT THE
KOPPERS SUPERFUND SITE
ARE DESIGNED TO
INFORM THE PUBLIC OF THE NATURE OF THE ENVIRONMENTAL ISSUES ASSOCIATED WITH THE SITE,
INVOLVE THE PUBLIC IN THE DECISION-MAKING PROCESS THAT WILL AFFECT THEM,
INVOLVE THE PUBLIC IN THE RESPONSES UNDER CONSIDERATION TO REMEDY THESE ISSUES, AND
INFORM THE PUBLIC OF THE PROGRESS BEING MADE TO IMPLEMENT THE REMEDY.
IN RESPONSE TO THE COMMUNITY, EPA WILL REVIEW THIS COMMUNITY INVOLVEMENT PLAN
(CIP) SIX MONTHS AFTER THE RELEASE DATE AND DETERMINE IF A REVISION IS NECESSARY.
Koppers Superfund Site
Community Involvement Plan October 1, 2010
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Table of Contents
Section Page
1.0 Overview of the Community Involvement Plan 1
2.0 Capsule Site Description 2
2.1 Site Background 2
2.2 Site Investigations and Cleanup Activities 4
3.0 Community Background 11
3.1 Community Profile 11
3.2 History of Community Involvement 12
3.3 Key Community Concerns 13
3.3.1 Former Community Concerns 13
3.3.2 Current Community Concerns 13
4.0 EPA's Community Involvement Program 15
4.1 The History of the Development of the CIP 15
Tables
2.1 Identified Site Contaminants of Concern 3
2.2 Site History 8
2.3 Superfund Cleanup Process 10
3.1 Summary of Current Community Concerns and EPA Responses 14
4.1 Time Frame Summary for Community Involvement Activities 20
Figure
2.1 Site Layout 4
Appendices
A EPA Regional Contacts
B Local Officials
C Federal and State Officials
D Affiliated Agency Contacts
E Environmental and Active Citizens Groups
F Media Contacts
G Meeting Locations
H Comments from the Public for the Final CIP
I Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
J Glossary
K Demographic Information
L Summary of Public Involvement and Outreach
May 2011 Revisions: ROD checked as completed; February 2, 2011 date added to checklist for Responsiveness
Summary (as part of ROD) issued via Press Release and Web Site; May 2011 dated added as 6-month update for
CIP; and Appendix L added to show Public Involvement and Outreach activities.
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Community Involvement Plan October 1, 2010
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Section 1.0
Overview of the Community Involvement Plan
The United States Environmental Protection Agency (EPA) developed the Community
Involvement Plan (CIP) to serve as a framework for community involvement and outreach
efforts associated with the Koppers Superfund Site (the Site). The CIP addresses the relationship
between the Site, the community, and EPA; provides a background of the community; presents
EPA's community involvement program; and provides a listing of resources. The goals of the
CEP are to inform the public of planned and ongoing site activities; maintain open
communication about site remediation; ensure that former concerns are acknowledged and
addressed; provide interested parties with useful information; provide citizens with opportunities
to comment on and be involved in technical decisions; and encourage and assist local citizens in
providing input to agency decisions that will have long-term effects on the community.
Information discussed during community interviews and Site documents are both essential
elements in developing the CEP. The Draft CIP was submitted and made available to the public
for public comment on August 16, 2010. Comments from the public were reviewed by EPA and
were considered for the revision of the Draft CIP. The modified Draft CEP was published on
October 1,2010.
The CEP is revised as community concern warrants or at minimum, every three years until site
activities have been concluded. The revision process includes conducting additional community
interviews, updating mailing lists, investigating the designated repository, and updating the
contacts and resources provided in the Appendices of the CIP. The purpose of the revision
process is to ensure that both previous and current needs and expectations specified by the
community are acknowledged.
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Section 2.0
Capsule Site Description
2.1 Site Background
The Site covers approximately 140 acres which bridge two properties: the Koppers Corporation
(Koppers) and Cabot Carbon Corporation (Cabot); each of which presents a unique challenge to
the Site's proposed remedial actions. The Site is located in the northern portion of the City of
Gainesville, Alachua County, Florida. Single family and multiple family residential properties
are located to the immediate west of the Site and commercial facilities border the southern and
eastern portions of the Site along Northwest 23rd Avenue and North Main Street, of which the
Stephen Foster Neighborhood is the closest to the Site.
Wood-treating operations were conducted on the Site, which is currently owned by Beazer East,
since the early 1900s. Poor waste handling practices adopted during these operations resulted in
contaminated groundwater, soil and possibly off-site surface water. The contaminants of
concern identified as Site-related include arsenic polycyclic aromatic hydrocarbons (PAHs),
dioxin, and creosote compounds. Table 2.1, Identified Site Contaminants of Concern, presents a
thorough list of the contaminants associated with the Site activities. Two potentially responsible
parties (PRPs) are funding the cleanup, Beazer East, Incorporated (Beazer) is the PRP for
Koppers and Cabot is the PRP for the remainder of the Site.
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Table 2.1 Identified Site Contaminants of Concern
CONTAMINANT
1-METHYLNAPHTHALENE
2,4-DIMETHYLPHENOL
2,4-DIMTROTOLUENE
2-CHLORONAPHTHALENE
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
ARSENIC
BENZENE
BENZO(B)FLUORANTHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZO[A]ANTHRACENE
BENZO[A]FLUORANTHENE
BENZO[A]PYRENE
BIS(2-
ETHYLHEXYL)PHTHALATE
CAMPHOR
CARBAZOLE
CHROMIUM
CHRYSENE
roENTIFEED
MEDIA
GW*
GW, SOIL, SW**
SOIL
SOIL
GW, SOIL, SW
GW, SOIL
GW, SOIL
GW, SOIL
GW
GW, SOIL
SOIL
GW, SOIL
GW, SOIL
GW
SOIL
GW, SOIL, SW
GW, SOIL, SW
GW
GW, SOIL, SW
SOIL
CONTAMINANT
COPPER
DIBENZO(A,H)
ANTHRACENE
DIBENZOFURAN
ETHANOL
ETHYLBENZENE
FLUORANTHENE
FLUORENE
INDENE
INDENO(1,2,3-CD)PYRENE
NAPHTHALENE
PAH
PAHs (POLYCYCLIC AROMATIC
HYDROCARBONS)
PENTACHLOROPHENOL
PHENANTHRENE
PHENOL
PYRENE
VOC
IDENTIFIED
MEDL4
SOIL
SOIL
GW
GW
GW
GW, SOIL
GW, SOIL, SW
GW, SW
SOIL
GW, SOIL, SW
SOIL
GW, SOIL
GW, SOIL
GW, SOIL
GW, SOIL, SW
GW, SOIL
GW, SW
* GW represents Ground Water
**SW represents Surface Water
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2.2 Site Investigations and Cleanup Activities
Koppers Portion of the Site
The Koppers site is a former wood
treating facility located on Northwest
23rd Avenue and comprises the
western portion of the Site (Figure 2.1,
Site Layout). It measures
approximately 90 acres in size. Wood
treating activities were conducted on
this portion of the Site since the early
1900s. Specific by-products detected
on the Koppers portion of the Site
include creosote, pentachlorophenol,
and copper-chromium-arsenic (CCA).
Two wastewater ponds, a former
cooling pond/process area, and a drip
track area were identified in this
portion of the Site. Investigations
performed by Koppers in the 1980s
revealed soil and groundwater
contamination on-site.
In 1985, the Department of
Transportation (DOT) proposed to
widen a portion of North Main Street,
adjacent to the Koppers site,
estimating that 4,800 cubic yards of
contaminated muck were unsuitable for roadbed material and needed to be removed. The
Florida Department of Environmental Regulation (FDER, now FDEP) identified feasible
alternatives for disposal of the muck in its March 1986, "Assessment of Management
Alternatives for North Main Street Muck - Gainesville, Florida."
In December 2009, Koppers announced its agreement for the sale and transfer of the property
and buildings to Beazer.
Figure 2.1 Site Layout
,rd
Cabot Portion of the Site
The Cabot site is located in Gainesville, Florida near the intersection of Northwest 23IU Avenue
and North Main Street in Section 29, Township 09S, Range 20E. Cabot served as a facility for
the destructive distillation of pine stumps and existed on the 49 acres site from 1945 to 1965.
During Cabot's operation, approximately 6,000 gallons of crude wood oil and pitch were
generated daily. Process wastewater containing residual pine tar was discharged to unlined
surface impoundments, and the accumulated tar was periodically scraped-out and sold. The
property was subsequently sold to a local developer who drained the ponds and allowed phenolic
contents to flow off-site through an adjacent 50 acre wetland and into a storm water ditch
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connecting with Springstead and Hogtown Creeks. Hogtown Creek traverses through the City of
Gainesville and terminates at Haile Sink, which is approximately 14 miles away.
Cabot was sold to another developer in 1967. As a
part of the process to commercialize the area where
the Site was located, the product lagoons were
breeched and as a result, pine tars and oils were
discharged to the surrounding wetlands and creek.
The remaining lagoon sludge was mixed with site
soils. Later, a shopping center, car dealership, and a
series of smaller stores and businesses were built on
the site and storm water ponds were constructed on
top of the former lagoons.
Car lot located on the former Cabot site
Malodorous leachate appeared in the Main Street ditch
which initiated community concerns. Groundwater
samples were collected where exceedances in wood-
preserving related contaminants were detected. As a
means to quickly address the exceedances, a trench was
installed along Main Street as well as partial excavation
of the northeast lagoon.
A complaint against Cabot and Mr. Raymond Tassinari
was filed by FDER in July 1983 for violation of Florida
Statutes and FDER regulations. In June 1984, judgment
was ruled in the favor of Mr. Tassinari. Through this
ruling, Mr. Tassinari was offered cost recovery. However, implementation of the ruled cost
recovery would not be conducted until completion of the Remedial Investigation/Feasibility
Study (RJ7FS). In 1995, FDEP completed cost recovery against the responsible parties, Beazer
and Cabot.
Shopping center located on the former Cabot
site
Planning
In December 1984, FDER entered into a Superfund Cooperative Agreement with EPA to
conduct a RI/FS. In April 1987, upon the completion of the draft Remedial Investigation (RI)
report, FDER held an informational meeting in Gainesville to present the results and answer
questions discussed in the draft RI/FS. The final RI report was received in June 1987.
In November 1987, the EPA-FDER Cooperative Agreement expired resulting in EPA taking the
lead management role to the Site's remedial action. As a part of this lead, a Consent Order was
entered with EPA and the PRPs, Cabot and Beazer. The final RI Addendum was issued in
November 1989 which confirmed that elevated levels of site-related contaminants were detected
in the groundwater (Koppers and Cabot), soils (Koppers), and sediments located in the North
Main Street ditch and Springstead Creek. The Risk Assessment which concluded that
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contaminant levels did not pose a health risk under current industrial/commercial land use
practices and final Feasibility Study (FS) were approved in February and June 1990,
respectively.
In August 1990, the EPA signed the Record of Decision (ROD) documenting the selected Site
remedy for the Site. The remedy involved soil washing, bioremediation, and solidification/
stabilization of contaminated soils identified on the Koppers site; and surficial aquifer
groundwater recovery at both the Koppers and Cabot facilities, with treatment prior to discharge
to the local publicly owned treatment works (POTW). Soil cleanup criteria were selected based
on future residential use of the Site and the protection of groundwrater. Groundwater cleanup
goals were health-based and assumed potential use as a drinking water source.
In March 1991, Cabot signed a Consent Order with EPA agreeing to perform remedial design
and cleanup. Beazer agreed to perform remedial design and cleanup at the Koppers site in
response to the EPA's administrative unilateral order. Cabot developed a remedial design
describing the means of addressing the identified exceedances in both the soil and groundwater
media which included a groundwater interceptor. The Cabot Groundwater Remedial Design was
approved in December 1993.
Construction Studies Conducted by Cabot
Construction of the Cabot groundwater interceptor trench began in January 1995 following the
completion of the widening of North Main Street adjacent to the Site. Contaminated soil located
beneath North Main Street was excavated and treated off-site during DOT's road widening
activities. Installation of the Cabot groundwater recovery system was completed in May 1995.
Operation and Maintenance (O&M) of the surficial aquifer groundwater remediation system is
ongoing. Cabot performed additional field work in the former clock tower area where three
Floridan aquifer wells originally utilized during the former Cabot operations were plugged and
abandoned in 2000.
Construction Studies Conducted by Beazer
Beazer completed a groundwater and soil treatability study and a groundwater pretreatment
design in September 1993. Subsequently, construction of the groundwater recovery and
pretreatment system was completed in November 1994. Operation of the Koppers groundwater
recovery and pretreatment system is ongoing. Beazer conducted a preliminary evaluation of the
existing surficial groundwater remedial system in December 2006 which was followed by more
widespread sampling of surficial aquifer monitoring wells in 2007. Based on these results,
Beazer implemented a surficial aquifer Interim Remedial Measure in May 2009 with
modifications to the existing Koppers system. These modifications would increase the volume
of contaminated groundwater removed in the on-site source areas and reduce the vertical
movement of contaminated groundwater deeper into the aquifer.
Initial design sampling for the 1990 selected Superfund remedy indicated that a much larger
volume of soil contamination might exist at Koppers along with dense non-aqueous phase liquid
(DNAPL) contamination below the water table. Additional DNAPL assessment and re-
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evaluation of the Site remedy was conducted and reported by Beazer in the September 1999
Revised Supplemental FS. EPA provided a separate FS Addendum with further evaluation of
cleanup alternatives in April 2001. In response to the approved FS, EPA held a public meeting
in May 2001 to present the proposed plan for an amended soil remedy. The proposed remedy
consisted of an impermeable cap and underground slurry wall to contain contaminated soil and
the underlying DNAPL creosote contamination in the surficial aquifer. The Gainesville
Commission formally opposed the proposed containment remedy, citing concerns that the
underlying clays were not adequate to prevent contaminant migration into the underlying
Hawthorn formation and Floridan aquifer. FDEP expressed similar concerns and also indicated
that off-site soil sampling should be completed to determine if site-related contamination
including dioxin was present in the adjacent neighborhood.
As instructed by the EPA, Beazer conducted additional field work at the Koppers site to
determine the continuity of the underlying Hawthorn clays, the extent of contamination, and the
feasibility of the proposed containment remedy. Assessment activities from 2001 to present
included: a) installation and monitoring of additional on-site wells in the shallow, intermediate
and deep Hawthorn and upper Floridan Aquifer; b) DNAPL assessment including coring in or
near the four on-site source areas; c) completion of a private well survey and sampling of off-site
private potable wells west and north of the site; d) installation of additional off site Hawthorn
monitoring wells east and west of the Koppers property; e) additional on-site soil sampling; and
f) off-site soil sampling west of the Koppers facility. There are currently 38 Hawthorn and 33
Floridan Aquifer monitoring wells including 19 multi-level Floridan wells and four off-site
"sentinel" Floridan wells at the Koppers site. Installation of additional Floridan monitoring wells
is currently underway.
Conclusions from Studies
Groundwater
Data presented in the September 2002, August 2003, and September 2004 Field Investigation
Reports, the July 2006 and October 2007 Floridan Aquifer Well Installations reports, the March
2008 Supplemental Hawthorn Group Investigation report, and subsequent ongoing groundwater
monitoring results have confirmed that contaminants including phenolic compounds and creosote
related compounds including PAHs and naphthalene have migrated from the surficial aquifer
into the underlying Hawthorn formation and upper Floridan aquifer, at depths up to
approximately 200 feet below land surface
Stormwater
Monitoring by Koppers of on-site storm water has confirmed exceedances of the "benchmark
criteria" in the DEP storm water permit for arsenic and copper. A comparison to surface water
standards indicates that arsenic is also above the FDEP surface water standard in on-site storm
water. The on-site Koppers ditch conveys storm water off-site and ultimately to Springstead
Creek. Federal and State regulations require the operating facility to comply with waste
management protocols designed to prevent contaminant releases. Excavation of contaminated
sediments in the on-site storm water ditch was completed by the Koppers facility in 2009 in an
effort to address the current general storm water permit exceedances. Koppers submitted an
application for an individual FDEP storm water permit which would require monitoring of
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facility specific constituents to determine compliance with storm water regulations and identify
any necessary subsequent corrective actions.
Soil
Beazer submitted an evaluation of possible interim actions, including an interim soil removal, to
address surficial contaminant sources. Additional on-site soil sampling results were reported in
October 2007 to support an update of the risk assessment and soil cleanup criteria, as well as the
selection of a final soil/source remedy. The results depicted widespread on-site dioxin
contamination in soils above State industrial use criteria as well as arsenic and some PAHs.
FDEP and local agencies recommended off-site soil sampling to determine the horizontal extent
of contamination. In response to the recommendation, off-site soil sampling in a City easement
and Right of Ways (ROWs) in the residential neighborhood west of Koppers was initially
conducted in early 2009.
Additional sampling is underway to determine the off-site extent of the contamination west of
the facility. Results to date indicate that the top six inches of soil located in ROW samples up to
300 feet west of the site contain dioxin, arsenic and carcinogenic PAHs at concentrations above
the State cleanup target levels for unrestricted residential use. Early events in the chronology of
the site history are depicted in Table 2.2.
Table 2.2 Site History
Time Period
1989
1990
1995
2004
2007
2008
Event
Site was included on the National Priorities List
Health Assessment conducted by the State of Florida's
FDEP
Remedial Action plans confirmed
Risk Assessment conducted by FDOH
Groundwater Transport and Flow Modeling Work Plan
submitted
Five Year Review and Off-site Sampling Plan
Interceptor Trench Investigation and Feasibility Study
Current Activities
Additional sampling and remediation is on-going for the Koppers site. On July 15, 2010, EPA
released a Proposed Plan for a site-wide cleanup which addresses on and off-site soils/sediments,
surface water, and groundwater. Appendix I, Proposed Plan Follow-Up Preferred Remedy Fact
Sheet, September 2010, provides a detailed discussion surrounding the proposed cleanup
activities for the Site.
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Table 2.3 Superfund Cleanup Process
Event
PA/SI
Complete?
Description
Preliminary Assessment/Site Inspection
Investigations of site conditions. If the release of hazardous
substances requires immediate or short-term response actions,
these are addressed under the Emergency Response program of
Superfund.
NPL Listing
RI/FS
ROD
National Priority List (NPL) Site Listing Process
A list of the most serious sites identified for possible long-term
cleanup.
Remedial Investigation/Feasibility Study (RI/FS)
Determines the nature and extent of contamination. Assesses
the treatability of site contamination and evaluates the potential
performance and cost of treatment technologies.
ROD
Explains which cleanup alternatives will be used at NPL sites.
When remedies exceed 25 million, they are reviewed by the
National Remedy Review Board.
RD/RA
Construction
Completion
Remedial Design/Remedial Action (RD/RA)
Preparation and implementation of plans and specifications for
applying site remedies. The bulk of the cleanup usually occurs
during this phase. All new fund-financed remedies are
reviewed by the National Priorities Panel.
Construction Completion
Identifies completion of physical cleanup construction, although
this does not necessarily indicate whether final cleanup levels
have been achieved.
Post
Construction
Completion
NPL Delete
Reuse
Post Construction Completion
Ensures that Superfund response actions provide for the long-
term protection of human health and the environment. Included
here are Long-Term Response Actions (LIRA), Operation and
Maintenance, Institutional Controls, Five-Year Reviews,
Remedy Optimization.
NPL Deletion
Removes a site from the NPL once all response actions are
complete and all cleanup goals have been achieved.
Site Reuse/Redevelopment
Information on how the Superfund program is working with
communities and other partners to return hazardous waste sites
to safe and productive use without adversely affecting the
remedy.
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Section 3.0
Community Background
3.1 Community Profile
Gainesville is the largest city and county seat of
Alachua County and serves as the cultural,
educational, and commercial center for the North
Central Florida Region. The City of Gainesville
provides a full range of municipal services, including
police and fire protection; comprehensive land use
planning and zoning services; code enforcement and
neighborhood improvement; streets and drainage
construction and maintenance; traffic engineering
services; refuse and recycling services through a
franchised operator; recreation and parks; cultural
and nature services; and necessary administrative
services to support these activities. Additionally, the
City of Gainesville owns a regional transit system, a
municipal airport, a 72-par championship golf course,
and a utility.
Photograph depicting the protests
sponsored by the community
Gainesville is home to Florida's largest and oldest university
and is one of the state's centers of education, medicine,
cultural events, and athletics. The University of Florida and
Shands Hospital at the University of Florida are the leading
employers in Gainesville and provide jobs for many residents
of surrounding counties. Known for its preservation of
historic buildings and the beauty of its natural surroundings,
Gainesville's numerous parks, museums and lakes provide
entertainment to thousands of visitors. Because of its
beautiful landscape and urban "forest", Gainesville is one of
the most attractive cities in Florida. Santa Fe College also
provides extensive education to the community.
Implementation of community awareness has been a top
priority for the City of Gainesville through initiatives such as
Dismantling Racism which focus on race and race
relationships in the City of Gainesville, Florida.
The City of Gainesville has a Council/Manager form of government which means that the Mayor
and City Commission make policy decisions; and the staff, led by the City Manager, implements
these decisions.
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3.2 History of Community Involvement
Community involvement has been established by EPA since the discovery of the Site. Several
public meetings were held to discuss the status of the Site's remedial action over the period of
the Site's existence. Upon the Site's inclusion to the National Priority's List (NPL) in August
1983, public awareness and education were offered to the affected community. The first form of
education provided to the community was a health assessment which was conducted by Agency
for Toxic Substances and Disease Registry (ATSDR) in April 1989 for the Site. A group of
public meetings were facilitated by EPA for the community in regards to the remedial action for
the Site from 1989 through 1990. The purpose of these meetings is to educate the community on
the remedial action and the process that the remedial action will take. In August and September
1990 a formal public comment period for the RI/FS was held.
A Twp ii Jiwd*^uj1« le *ddr*tf tfalt
A depiction of the community's perception of the
remedial action
At the conclusion of the remedial action, several
meetings surrounding the five year review status
of the Site were held to discuss the efficiency of
the cleanup activities. Following the
implementation of the remedial action, the
community was educated on the purpose and
process of selecting a Technical Assistance Grant
(TAG); future reuse of the Site as well as the risk
assessment of the off-site soils.
The community has played an active role in
presenting their concerns regarding the remedial
action to the public by protesting in front of the
Koppers plant prior to its closure as well as
facilitating and hosting their own individual group
meetings. Media attention has played an integral
part in educating the community on the Site-related
activities. On April 20, 2010, seven Gainesville
residents filed a lawsuit against Beazer Koppers
Incorporated, Beazer, and the Boston-based Cabot
Corporation for $500 million which will in turn,
support the analysis and cleanup of the
contaminants of concern at those properties that are
presumably contaminated.
3.3 Key Community Concerns
The community concerns discussed in this section
of the CIP are divided into two parts; former and
current. The former community concerns are those that were documented/mor to the
preparation and implementation of the off-site remedial action proposed plan meeting held on
August 5, 2010.
The TAG was awarded to the Protect
Gainesville's Citizens, Incorporation
Protect Gainesville's Citizen, Inc.
802 W. University Avenue
Gainesville, FL 32601
Phone 352-262-2442
Contact: Cheryl Krauth
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EPA conducted community interviews with local residents on July 8, 2010 to discuss the
modified remedial action issued for the Site after which, a public meeting facilitated by EPA was
scheduled. The major concerns highlighted during the interviews involved the need for more
efficient communication among the PRP, EPA, and the community as well as the determination
of the extent of contamination detected off-site.
3.3.1 Former Community Concerns
Former community concerns include the risk assessment conducted for the groundwater and
surface water media. The community felt uncertain with the selected remedial design as there
was not a thorough design proposed. Community concerns involved the following:
• Dust suppression and air particulate gauging;
• Overall remedial action and its efficiency;
• Risk assessment which determined the remedial action issued for the cleanup;
• Precaution to ensure no further contamination from on-going manufacturing operations,
especially in stormwater;
• Redevelopment of the Cabot site;
• North Lagoon remedial action; and
• Public health concerns as several persons complained of foul odors that originated from
the Site as well as unexplained illnesses.
EPA provided responses to these concerns by assuring the community that the Site is undergoing
remedial action that will effectively address the aforementioned concerns.
3.3.2 Current Community Concerns
The community concerns that have been presented to EPA in regards to the off-site
contamination consist of the following:
• Consistent communication is needed among EPA, the PRP, and the community;
• Efficiency of the remedial action proposed for the off-site contamination;
• Revision of the FS;
• Extension of the public comment period;
• Development of the CIP; and
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• Conduct more thorough investigations surrounding the extent of contamination.
Table 3.1, Summary of Current Community Concerns and EPA Responses, presents a summary
of the major concerns expressed by the community during the community interviews and public
meeting held in July of 2010.
Table 3.1 Summary of Current Community Concerns and EPA Responses
Concerns
Responses
Remedial Investigation/Feasibility Study (RI/FS) is not
defensible as the risk assessment is unclear and the
regulatory languages are not consistent (i.e., State versus
Federal regulations).
It is best to review the material provided in the
repository and participate in the public comment penod
as further information will be provided that may provide
support to the risk assessment and opportunities to
present concerns will be available.
Requested basic information sessions though it seems
EPA is not taking the community seriously. The
remedial processes are not considering the needs of the
community. The community recently identified a
Technical Advisor who will have approximately two
weeks to review all Site-related documents before the
Public Comment Period.
EPA supports community engagement and will provide
sessions for the community to become more educated on
the remedial action process as well as common
terminology.
The public meeting with EPA contractor E-Squared (E2)
seemed to be put E2 in the middle of the community and
EPA. It seemed as if EPA used E2 as a decoy from the
remedial process. At this point, the community feels as
though reuse/redevelopment information is inadequate
as remediation has not been completed or adequately
addressed.
EPA will continue to investigate means of reuse and
redevelopment for the Site at the conclusion of the
remedial action issued for the cleanup of the off-site
contamination. EPA also supports interagency
communication where all involved parties are provided
the opportunity to thoroughly research all options and
discuss them with EPA prior to the implementation of
any decision.
Administrative Record (AR) is not user-friendly as
documents are confusing. Feasibility Study (FS) relied
on previous studies which are not readily available for
public use such as the groundwater monitoring data and
risk assessment (parts were rejected and other parts were
not). The community also expressed concern with the
timing of the provision of the AR and the challenges that
it presents to the TAG recipient to review prior to the
submittal of the Proposed Plan.
EPA provided the AR for the community to review all
approved documentation regarding the remedial action
for the Site's cleanup. The AR is located at the Site's
designated repository and is available to the public. The
EPA conducts repository checks every three years to
ensure the availability of all documents referred in the
AR. Should it be necessary, EPA will conduct a
repository check to ensure the quality of the information
provided in the AR and its availability.
EPA will continue to provide inter-agency support by
including local governments and community partners in
public meetings.
Requested the participation of local government in the
remedial process with the community.
Concerned with off-site contamination as high dioxin
levels were detected in residential properties.
Groundwater was also tested and was identified to have
contamination detected as well.
Further investigations surrounding the extent of
contamination for both the groundwater and soils will be
addressed in the Proposed Plan. Should a particular area
be of concern, it is suggested that the information be
provided to EPA for further examination.
Appropriate storm water management does not appear to
be a part of the remedy. PRP proposed a remedy for
storm water management which may not be adequate.
Stormwater management is being addressed in the
Proposed Plan. Specific comments should be made in
regards to the storm water management during the public
comment period.
Koppers Supetfund Site
Community Involvement Plan
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May 2011
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Concerns
Can the community push for re-zoning developments?
The community is concerned that EPA's schedule is not
in compliance with theirs as the push for the proposed
plan meeting is not considering the selection of the
technical advisory group.
Community outreach with the Stephen Foster
neighborhood was discussed as a large number of the
residents are elderly and are limited in computer access.
City and County officials desired to be more involved in
the community and public outreach by having more
notice in public meetings to ensure no scheduling
conflicts.
Informational sessions provided by EPA to better
educate the community of the proposed remedial action.
The inconclusive nature of the FS.
Residential indoor air sampling not being conducted by
EPA.
Residential soil sampling not fully conducted by EPA.
Relocation for affected community persons.
Effectiveness of the proposed remedial action.
Responses
The local government and community will have to make
that decision as EPA cannot. The local community
would have to present their desires for a particular area's
zoning to their local government.
EPA extended the period of public comment beyond the
required 30 days to provide ample time for the public to
review all technical documentation. (90 day comment
period)
EPA can provide education on the current status of the
Site to ensure that all residents are provided information.
EPA will hold to the commitment of informing the local
government and community prior to finalizing the
proposed meeting dates and times to ensure full
participation.
EPA will provide an availability session to the
community pnor to the conclusion of the public
comment period. These sessions are informal and open
to involve the discussion of the Site activities, proposed
remedial action, and other Site-related topics.
Community persons presented concerns with the
ineffective conclusion the FS provided as there were
concerns surrounding areas that were not addressed such
as the burial area, groundwater contamination, and
residential properties. All comments will be addressed
in a Responsiveness Summary after the comment period
is concluded.
EPA will continue to review data and will make a final
determination on this concern.
EPA will continue to review data and make a final
determination.
Relocation is not a factor that the EPA mandates, but that
private land owners and the PRP could discuss through
review of their own financial agreements concerning any
restrictions that are associated with the individual
properties (based on site data).
The community expressed an ineffective nature of the
proposed remedial action and is suggesting that it seems
as if the contamination is not being cleaned but covered
by a tarp. EPA works to ensure that the selected
remedial action implemented at the Site will achieve
cleanup goals and promote the well-being of the general
public and the environment.
Koppers Supetfund Site
Community Involvement Plan
Page 14
May 2011
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Section 4.0
EPA's Community Involvement Program
The overall goal of EPA's community involvement program is to promote communication
between citizens and the EPA and to provide opportunities for meaningful and active
involvement by the community in the cleanup process. EPA will implement the community
involvement activities described below. The following plan is based on the results of the
community interviews described earlier; it addresses each issue that was identified as being
important to the community.
4.1 The History of the Development of the CIP
Issue 1; Maintaining the Most Current Site Information for the Public
Activity 1A: Establish a liaison for the Community and the EPA
• Objective: To provide a primary liaison between the community and the EPA, and to
ensure prompt, accurate, and consistent responses and information dissemination about
the Site. In those instances where EPA's CIC may be unable to provide adequate
information (such as on technical issues), inquiries will be directed to the appropriate
EPA contact.
• Method: EPA will designate an EPA CIC to handle site inquiries and serve as a point of
contact for community members. The CIC is appointed by Region IV. Ms. L'Tonya
Spencer serves as the EPA CIC assigned to the Site. She will work closely with Mr.
Scott Miller, EPA's RPM.
• Timing: The CIC was became actively involved in 2008.
Activity IB: Prepare and Distribute Site Fact Sheets and Technical Summaries
• Objective: To provide citizens with current, accurate, easy-to-read, easy-to-understand
information about the Site.
• Method: Fact sheets will be mailed to all parties on the Site mailing list. In addition,
copies will be available at the information repository, the Web, and other locations as
identified by the Community.
• Timing: EPA will prepare and distribute fact sheets as needed.
Activity 1C: Provide a Toll-free "800 Number"
• Objective: To enable citizens to get the latest information available when they want it,
rather than having to wait for a meeting or a fact sheet, and without incurring any cost.
Koppers Sitperfund Site
Community Involvement Plan Page 15 May 2011
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• Method: EPA will activate the 800 number and publish it periodically in the local papers
and in all fact sheets.
• Timing: The line is currently operational (1-877-718-3752).
Activity ID: Development of a Mailing List for the Site.
• Objective: To facilitate the distribution of site-specific information to everyone who
needs or wants to be kept informed about the Site.
• Method: EPA will create a mailing list that includes all residences adjacent to the Site, in
known or suspected paths of migration, or those otherwise affected by the Site. EPA will
also solicit interested parties via fact sheets, newspaper articles, public meetings, public
availabilities, etc.
• Timing: EPA has developed a Site Mailing List and an e-mail list, which will be updated
as needed.
Activity IE: Establishment and Maintenance of the Designated Information Repositories
• Objective: To provide a convenient location where residents can go to read and copy
official documents and other pertinent information about the Site and EPA activities.
• Method: The repository is a reference collection of site information containing the
Administrative Record file, other site-specific information, the CIP, information
pertaining to the TAG program, and the general Superfund process. The designated
repository is accessible to the physically challenged, will have copier facilities, and will
be available to residents during normal business hours and at least some evening and/or
weekend hours. Additional repositories may also be established, including one at EPA
Region IV.
• Timing: EPA established the local repositories at the Alachua County Library located at
401 East University Avenue; Gainesville, Florida 32601. EPA will continue to provide
additional documents as they become available.
Activity IF: Provide Site and Superfund Information on the Internet
• Objective: To provide key resources for searching and listing both general and specific
information pertaining to the Superfund and hazardous waste issues.
• Method: General information about EPA and Superfund can be found at the following
web site URL addresses:
EPA Headquarters: http://www.epa.gov
EPA Region 4: http: //www. ep a. go v/Region4/
The Proposed Plan and the ROD will be placed on the internet as they are completed.
Koppers Superfund Site
Community Involvement Plan Page 16 May 2011
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• Timing: Site Status Summaries are updated periodically.
Activity 1G: Provide TAG Information
• Objective: To provide resources for community groups to hire technical advisors who
can assist them in interpreting technical information about the Site.
• Method: EPA will provide information about the TAG program at public meetings and
in Site fact sheets. EPA will also provide briefing sessions to interested groups as
requested. EPA will provide TAG applications and assistance to qualified groups.
• Timing: EPA awarded the TAG to Protect Gainesville's Citizens, Incorporated in June
2010.
Activity 1H: Establish and Maintain the Administrative Record
• Objective: To provide residents with an index of all documents generated and referred to
by the EPA in the decision process of the Site remediation.
• Method: EPA will provide at least two sets of the Administrative Record. One will be
located at the EPA Region IV Office and one will be located at the the Alachua County
Library (the repository).
• Timing: The Administrative Record is generated at the beginning of site investigations.
Additions to the Administrative Record will continue to be included until the last ROD is
signed. EPA provided an updated Administrative Record to the community in June 2010.
Activity II: Development of the Community Involvement Plan
* Objective: The CIP is considered a living document, which means that it can be revised
at or before the standard three year term - refer to Activity 2D. This document provides
thorough discussion of the Site history, cleanup progress, community concerns,
community participation/events, and community contacts. The mission of the CIP is to
serve as a document that represents the community and its relation to EPA.
• Method: EPA will develop a draft CIP prior to cleanup activities and will present the
draft to the community for comments. All comments will be reviewed and, if necessary,
addressed in the CIP. The Final CIP will be available on the EPA webpage and
repository.
• Timing: The CIP is to be developed prior to initiating any cleanup activity. However,
due to the late timing of the established CIC, a CIP was not developed during the initial
Cabot-related cleanup activities and as a result, was not developed until the initial portion
of the Koppers cleanup phase in July 2010. A public comment period was offered to the
Koppers Sitperfund Site
Community Involvement Plan Page 17 May 2011
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community for the development of the Final CIP. The comments provided by the
community are presented in Appendix H, Comments from the Public for the Final CIP.
Issue 2: Provide Effective Opportunities for Community Involvement
Activity 2A: Schedule Public Meetings
• Objective: To inform the community on the most current Site developments and address
community concerns.
• Method: Refer to Appendix G for suggested meeting locations. EPA will schedule,
prepare for, and attend all announced meetings. EPA will provide at least two weeks'
notice of the scheduled meeting. The RPM, CIC, and other appropriate EPA personnel
will attend.
• Timing: Additional public meetings may be scheduled to continue updating the
community on the progress of the cleanup of the Site.
Activity 2B: Solicit Comments Generated During the Proposed Plan Comment Period
• Objective: To offer the community an opportunity to review and comment on various
EPA documents, specifically the Proposed Plan. This Public Comment Period will
provide the community opportunities to participate in the process and also provide EPA
and the PRP valuable information which will be considered during the decision process.
• Method: EPA will announce each comment period separately. Announcements will
appear in local newspapers and EPA fact sheets. The announcements will include
information regarding the duration of the public comment period and suggestions for
presenting and submitting public comments. EPA may request public comments
pertaining to public documents such as the CIP, preliminary findings, etc.
• Timing: The comment period is scheduled for July 15, 2010 through August 15, 2010.
The comment period was extended an additional 60 days.
Activity 2C: Prepare and Issue a Responsiveness Summary
• Objective: To summarize all submitted comments received during the public comment
periods as well as document the manner in which EPA has considered those comments
during the decision-making process. Response to the major comments will also be
provided.
• Method: EPA will prepare a Responsiveness Summary as a section of the ROD. The
Responsiveness Summary will include four sections: Overview; Background on
Community Involvement; Summary of Comments Received and Agency Responses; and
Remedial Design/Remedial Action Concerns. All information, both technical and
nontechnical, will be conveyed in a manner that is understood by all stakeholders.
Koppers Superfund Site
Community Involvement Plan Page 18 May 2011
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• Timing: EPA will issue the Responsiveness Summary as part of the ROD.
Activity 2D: Revision of the CIP
• Objective: To identify and address community needs, issues, or concerns regarding the
Site or the cleanup remedy that are not currently addressed in the previous CIP.
• Method: The Revised CIP will update the information presented in the previous version.
• Timing: EPA will revise the CIP as community concern warrants or at minimum, every
three years until the all Site activities have been concluded. It has been decided that this
CIP will be reviewed and considered for revision every six months from the release
date(s).
Koppers Superfund Site
Community Involvement Plan Page 19 May 2011
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Table 4.1 Time Frame Summary for Community Involvement Activities
ACTIVITY TIME FRAME DATE COMPLETED
Designate an EPA CIC
Prepare and distribute Site fact
sheets and technical summaries
Provide a toll-free "800 number"
for the community to contact EPA
Maintain a mailing list for the Site
Establish and maintain Information
Repositories
Provide Site and Superfund
information on the Internet
Provide Technical Assistance Grant
(TAG) information
Establish and maintain the
Administrative Record
Hold public meetings
Make informal visits to community
Solicit comments during a Public
Comment Period
Prepare and issue a Responsiveness
Summary
CIP Revision
A CIC is designated
throughout the entire duration
of the project.
As needed/warranted
Currently in operation
Established upon Site
discovery; updated as needed
Established; Update
documents as needed.
Repository investigations are
performed, at minimum, every
three to five years or as
needed.
Currently available; update as
needed
Completed for the award term
Established; update as needed
Ongoing; as needed
As needed
As needed and required
Following public comment
periods
As needed, at least every 3
years (6 month review for
additional comments)
2008
On-going
1-877-718-3752
1-800-435-9234
Ongoing
Repository has been
established and a
repository investigation
was performed in August
2010.
On-going
Protect Gainesville's
Citizens was awarded the
TAG in June 20 10
Re-established 2009
August 2010 (Proposed
Plan Meeting); October
2010 (Public Availability
Session)
On-going
July 2010 - October 2010
(extended 90 day comment
period)
Upon the conclusion of the
Public Comment as part of
ROD - Issued February 2,
201 1 via Press Release and
EPA Web Site.
November 2010; May 201 1
Koppers Superfund Site
Community Involvement Plan
Page 20
May 2011
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Appendix A
EPA Regional Contacts
The following is a partial listing of the EPA Regional Contacts designated to the Site progress.
Mr. Scott Miller Ms. L'Tonya Spencer
EPA Region 4 EPA Region 4
Superfund Division Community Involvement Coordinator
61 Forsyth Street, SW Superfund Division - OSPAO
Atlanta, GA 30303-8960 61 Forsyth Street, SW
Tel: (404) 562-9120 Atlanta, GA 30303-8960
Miller, scott@epa.gov Tel: (404) 562-8463
Spencer.latonva@epa. gov
Koppers Superfund Site
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Appendix B
Local Officials
The following is a partial listing of the local contacts that can assist with local emergencies in the
city of Gainesville and Alachua County area.
Mayor Craig Lowe
200 East University Avenue
Gainesville, FL 32601
Tel: (904) 387-8909
Email: mavorfgjcityofgainesville.org
Alachua County Board of Commissioners
P.O. Box 2877
Gainesville, FL 32602-2877
Tel: (352) 264-6900
Email: bocc(a),alachuacountv.us
Koppers Superfund Site
Community Involvement Plan
PageB-1
May 2011
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Appendix C
Federal and State Officials
The following is a listing of the State of Florida Officials.
Governor Charlie Crist Senator Bill Nelson
Office of the Governor 716 Hart Senate Office Building
State of Florida Washington, DC 20510
The Capitol Tel: (202) 224-5274
400 South Monroe Street Email: billnelson.senate.gov
Tallahassee, FL 32399-0001
Tel: (850) 488-4441
Koppers Superfund Site
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Appendix D
Affiliated Agency Contacts
The following is a partial listing of the affiliated agency contacts. The contacts may provide
additional historical information pertaining to the Site and current progress.
Florida Department of Environmental
Health
3900 Commonwealth Blvd
Tallahassee, FL 32399
Tel: (850) 245-2118
ATSDR Region 4
EPA - Waste, Region 4
Atlanta Federal Center
61 Forsyth St., SW
Atlanta, GA 30303
Tel: (404) 562-1788
Florida Association of Soil and
Water Conservation Districts
Administrative Consultant
16806 NW 40th PI.
Newberry, FL 32669
Tel: (3 52) 472-5462
Florida Department of Environmental
Protection
3900 Commonwealth Boulevard M.S. 49
Tallahassee, FL 32399
Tel: (850) 245-2118
Koppers Superfund Site
Community Involvement Plan
PageD-1
May 2011
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Appendix E
Environmental and Active Citizens Groups
The following organizations provide insight on environmental issues specifically focused on the
City of Gainesville.
Alachua County
Environmental Protection Department
Chris Bird, Director
201 SE 2nd Ave, Suite 201
Gainesville, FL 32601
Tel: (352) 264-6801
Email: chris@alachuacounty.us
Keep Alachua County Beautiful
602 S. Main St.
Gainesville, FL
Tel: (352) 371-9444
Conservation Fund
12 W. University Ave.
Gainesville, FL
Tel: (352) 264-7903
Alachua Conservation Trust
12 W. University Ave.; Suite 201
Gainesville, FL
Tel: (352) 373-1078
Protect Gainesville's Citizens (Technical
Assistance Grant-TAG Recipients)
Cheryl Krauth
802 W. University Avenue
Gainesville, FL 32601
Tel: (3 52) 262-2442
Koppers Superfimd Site
Community Involvement Plan
Page E-l
May 2011
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Appendix F
Media Contacts
The following is a listing of the television, radio stations, and newspaper media outlets that
provide service to the Alachua County area.
Radio Stations
WUFT 89.1
P.O.Box 118405
Gainesville, FL 32611
Tel: (352) 392-5200
Main: radio@wuft.org
WYFB 90.5
Bible Broadcasting Network
11530 Carmel Commons Blvd.
Charlotte, NC 28226
91.7 FM Studio
The Seagle Building
408 W. University Ave; Suite 206
Gainesville, FL 32601
Tel: (352) 373-9553
Smooth FM 100.9
WXJZ-FM
4424 NW 13th St.; Suite C-5
Gainesville, FL 32609
Tel: (352) 375-1317
E-mail: feedback@,wxjz.fm
ROCK104 Studio
University of Florida
3200 Weimer Hall
Gainesville, FL 32611
Tel: (352) 392-0771
KISS 105.3
7120 SW 24th Ave.
Gainesville, FL 32607
Tel: (352) 331-2200
AM850 - WRUF Radio
P.O. Box 14444
Gainesville, FL 32604
Tel: (352) 392-0771
Television Stations
WUFT-TV
P.O.Box 118405
Gainesville, FL 32611
Tel: (352) 392-5551
Email: info@wuft.org
WCJB TV20
6220 NW 43rd St.
Gainesville FL 32653
Tel: (352) 377-2020
Email: tv20news@wcjb.com
WOFL-FOX35
35 Skyline Dr.
Lake Mary, FL 32746
WGFL-CBS4
1703 NW 80th Blvd.
Gainesville, FL 32606
Tel: (352) 332-1128
Koppers Superfimd Site
Community Involvement Plan
Page F-l
May 2011
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Appendix F
Media Contacts (Continued)
Newspapers
INsite Magazine
The Gainesville Sun 1010-B NW 8th Ave.
P.O. Box 147147 Gainesville, FL 32601
Gainesville, FL 32614-7147 Tel : (352) 377-6602
Tel: (352) 378-1411
Senior Times
The Independent Florida Alligator 4400 NW 36th Ave
1105 W. University Ave. Gainesville, FL 32606
Gainesville, FL 32601 Tel: (352) 372-5468
Tel: (352) 376-4458
Koppers Superfund Site
Community Involvement Plan PageF-2 May 2011
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Appendix G
Meeting Locations
The information provided below relates to the locations of the facilities designated for public
review of all Site documents and public meetings.
Information Repositories and Public Meeting Locations:
Stephen Foster Elementary
3 800 NW 6th St.
Gainesville. FL 32609
Tel: (352) 955-6706
Santa Fe College Board Room
3000 NW 83rd Street
Gainesville, FL 32606
Tel: (352) 395-5000
Alachua County Library District Headquarters
401 E. University Avenue
Gainesville, FL 32601
Tel: (352) 334-3900
Eastside Community Center
2841 East University Avenu
Gainesville, FL 32601
Tel: (352)334-2714
Contact: Mr. Ross
For Availability: (352) 334-2189
Contact: Ms. Virgina Shay
Koppers Superfund Site
Community Involvement Plan Page G-1 May 2011
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Appendix H
Comments from the Public for the Revised CIP
Concern
Means of Addressing
Approximation of 2009 population estimate — suggested
that the reference for the population estimate for
Alachua County be the University of Florida Bureau of
Economic and Business Research (UF BEBR) as its
population estimate suggests 256,232 residents for
Alachua county with approximately 107,260 residents
living within unincorporated areas.
The population cited using the U.S. Census stated
approximately 243,574 residents in Alachua County (a
difference of 12,658 residents). To minimize confusion
with the document, a footnote reference was
incorporated in the appendix providing the estimate
presented by UF BEBR.
Focus on the entire Cabot site in the Site History section
of the CIP as opposed to the area of concern, the
Koppers site. Presenting such a focus gives a false
perception of the actual period where the CIP and EPA
community relations were established.
The Site history is an inclusive section of the CIP. For
many Sites where there maybe several sub-sites, as with
Cabot Koppers, the Site history will discuss all sub-
sections. The perception of EPA community relations
was never falsified in the document clearly states in
Section 4.1 - The History of the Development of the
CIP, that the EPA CIC was designated in 2008.
However, to further solidify this concern and continue
with the transparency of the EPA to the Gainesville
community, another activity, Activity II - Development
of the Community Involvement Plan, was included in
Section 4.1 which clearly discusses the un-tinieliness of
its publication in relation to the initial cleanup activity.
In addition, the title of the CIP has been modified from
the 'Cabot Koppers Community Involvement Plan' to
'Koppers Community Involvement Plan'. This is to
ensure the public's perception of the focus point of the
community plan.
Page 1 of the draft CIP: Factual error with the draft
publication date which is observed as the listed date of
August 9, 2010; however, the draft CIP was not made
available to the public until August 16. 2010.
The date was confirmed and modified to August 16,
2010.
Page 1 of the Draft CIP: Factual error with the 'wood-
treating operations activities being conducted since
1916'. Historical records indicate that these activities
were conducted prior to 1916.
The date of the wood-treating operations is confirmed
by EPA documents as 1916. However, the following
statement will be included in the CIP in regards to this
observation: 'Wood-treating operations were conducted
on the Site, which is currently owned by Beazer East,
since the early 1900s. A similar statement is presented
in Section 2.2 - Site Investigations and Cleanup
Activities, and has been modified to the aforementioned
statement.
Page 15 of the Draft CIP: Factual error was observed
with the toll-free number provided for community
concerns. This concern surfaced when the phone
number did not function properly. The number provided
was 1-800-718-3752.
This observation is correct. EPA modified the
community hotline in the revised CIP.
Koppers Supetfiind Site
Community Involvement Plan
Page H-l
May 2011
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Appendix H
Comments from the Public for the Final CIP (Continued)
Concern
Means of Addressing
Page 1 of the Draft CIP: Factual error was observed in
the first paragraph of the Draft CIP where it states, "The
Draft CIP was submitted and made available to the
public on August 9, 2010."
This is incorrect as the public was not provided the CIP
until August 16, 2010.
This observation is correct. EPA modified the Draft CIP
to provide the correct publication date.
Page 1 of the Draft CIP: The document briefly discusses
the types of contaminants of concern and media where
the contaminants are identified. However, the brief
number of contaminants discussed in this section does
not adequately characterize the full extent of the
contaminants that exist in the on and off-site areas.
To better discuss the nature and extent of contamination
identified in off- and on-site media, EPA provided a
table from the Cabot Koppers NPL website which
discusses the contaminants of concern.
Page 10 of the Draft CIP: The text reads, "The former
community concerns are those that were documented
prior to the preparation and implementation of the off-
site remedial action proposed plan meeting held on
August 4, 2010." The correct date for the meeting was
Thursday August 5, 2010.
This observation is correct. EPA modified the Draft CIP
to provide the correct public meeting date.
The CIP boiled the 300 or more documented citizens'
comments into seventeen (17) one-paragraph table
entries, many of which either do not properly
characterize the issue that was originally expressed, are
incomplete, or do not provide adequate answers to the
original issue.
This section was intended to summarize the major
community concerns and not create individual
statements for the document. The focus of this
document is to provide a general summary of the major
comments highlighted during the community interviews
and focus group meeting.
Table 3.1 of the Draft CIP: One of the biggest hot
button issues in the community (the one that sparked the
lawsuit) is this "concern" (listed on the second page of
the table): "Relocation for affected community persons."
EPA answered with this "response": "EPA will not
relocate any person affected by the Cabot Koppers Site
as contamination does not reflect alarmingly high
concentrations."
That's a really strong statement to make when you
consider the previous concerns/responses in the table,
where the EPA consents that it is unclear if more testing
needs to be done in residential dwellings and in
residential yards. It was apparent to the community, as
stated by EPA, that relocation was not something the
EPA mandates, but that private land owners and Beazer
could come to their own financial agreements about any
restrictions that get placed on the individual properties
(based on site data). The way this was answered here, it
makes it sound like EPA does have the power to issue a
relocation mandate to the PEP, but that they won't in this
case. And then the reasoning for why they/you won't
looks..."not based on good science."
The EPA reviewed and modified the response regarding
the relocation issue, with approval from EPA
Management, to reflect the response provided during the
public meeting.
Koppers Superfimd Site
Community Involvement Plan
Page H-2
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
U.S. ENVIRONMENTAL PROTECTION AGENCY
,,
^?
PROPOSED PLAN FOLLOW-UP
PREFERRED REMEDY FACT SHEET
September 2010
Cabot Carbon/Koppers Superfund Site
Gainesville, Alachua County, Florida
Introduction
This fact sheet, issued by the U.S.
Environmental Protection Agency (EPA)
provides clarification and additional information
about the preferred remedy in the Proposed Plan
for the Cabot Carbon/Koppers Superfund Site
(Site), Gainesville, Alachua County, Florida.
EPA presented the preferred remedy for the Site
during a public meeting held on August 5"',
2010. The KPA detennincd that it should
provide more details and clarification of the
preferred remedy in response to questions and
concerns voiced by the community during that
meeting. A separate fact sheet for off-Site soil
cleanup activities is being prepared.
This fact sheet provides a brief Site summary,
addresses specific components of the preferred
remedy, and discusses community concerns
relating to remedial activities. Off-site soil
cleanup concerns are addressed in a separate tact
sheet
Site Summary
The Cabot Carbon/Koppers Superfund Site is
located in a commercial and residential area of
the northern part of the Gainesville city limits,
Alachua County, Florida. This Site was
originally two Sites; Cabot Carbon in the
southeast portion of the Site, and Koppers on the
western portion of the Site (Figure I). Cabot
Carbon was a pine tar and charcoal generation
facility, but is now commercial property.
Koppers was an active wood-treating facility
until December 2009. Although remedial
investigations at the Cabot Carbon/Koppers Site
began in 1983 and are now completed, EPA will
Availability Session
Date: October 6, 2010
Time: 6:00 PM to 9:00 PM
Location: Eastside Community Center
2841 East University Avenue
Gainesville, Florida 32601
The community is invited to a public availability
session regarding the Cabot Carbon/Koppers Site.
Representatives from EPA, the Florida Department
of Health (FDOII), and the Alachua County
Knvironrnenlal Protection Department (ACBPD)
will be available to provide information and answer
questions about upcoming activities at the Site.
The Administrative Record file for the
Cabot Carbon/Koppers Site is available at the
following location:
Alachua County Library
401 E. University Ave.
Gainesville, FL 32601
(352) 334-3900
www aclib us/locations/headquarters
continue to collect sampling data for
groundwaler, soil, sediment, and surface water to
evaluate the effectiveness of the remedy over
time.
From this point forward, the word "Site" will
refer to the Koppers portion of the Cabot
Carbon/Koppers Superfund Site, unless
otherwise specified. The Site remedial action
will also address off-Site areas contaminated
Koppers Superfund Site
Community Involvement Plan
Page 1-1
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
I I i
JFORVEH DRIP -*J
- TRACK AREAS f
1000
SCALE IN FEET
2000
Figure 1.
Site Map
Cabot Carbon/Koppers Superfund Site. Gainesville, Rorfda
Koppers Superfund Site
Community Involvement Plan
Page 1-2
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
by Site-related activities, including residential
and industrial areas surrounding the Site and
Iloglown and Springstoad creeks to the north and
west of the Site. Site contamination is a result
of releases of wood-treatment chemicals. Four
potenlial source areas have been identified at the
Site (Figure 2). Site contaminants arc associated
with the historical use of creosote for wood
treating and include mobile and or residual dense
non-aqueous phase liquids (DNAPLs). DNAPLs
are organic substances that do not mix with and
arc heavier than water. Site contaminants also
include arsenic, polycyclic aromatic
hydrocarbons (PAHs), and dtoxins/tiirans in soil
sediment and groundwalcr. Itic most
predominant contaminant in groundwater is
PAHs, The Feasibility Study (FS) and Proposed
Plan provide lor additional details,
Preferred Remedy Description
line selected alternative is the result of years of
collaborative effort and thorough review on the
part of many organizations, including input from
local agencies and the public. The alternative is
robust and protective of human health and the
environment. Remedy selection is the final step
in the Supcrfund process before cleanup design
and action.
Hie preferred remedy will protect human health
and the environment by containing, treating, and
controlling contamination associated with the
Site. This remedy was selected over other
options evaluated because as a whole it was
determined to provide the optimal solution based
on Comprehensive Environmental Response.
Compensation and Liability Act (CKRCLA) FS
evaluation criteria. The selected remedy is
compatible with the anticipated future use of the
property, as described in more detail below.
The selected remedy has three parts that address
three distinct media groups: on-site media (soil
and groundwulcr above the Upper Floridan
Aquifer (UFA)). groundwaler in the UFA. and
off-Site media (soil, sediment, and surface
water), 'Hie major components of the three parts
of the remedy are summarized on Table 1 of this
fact sheet. Additional details on the preferred
remedy components are presented below. Off-
site soil cleanup concerns are addressed in a
separate fact sheet
Preferred Remedy Community
Concerns
On-site Soil and Groundwater Cleanup
The public has expressed concern about the
proposed on-site remedy. EPA is aware of the
public's concerns and in an effort to provide
additional information has prepared the
following specific responses to community
questions.
Why not dig up all DNAPL-impacted soil?
Excavation of source area soils containing
DNAPT. was evaluated in comparison with other
options during the FS process. The preferred on-
site remedy, summarized on Table L was
determined to be the optimal alternative based on
key criteria including remedy protectiveness.
Specific challenges associated with soil
excavation at the Site are;
/. Excavation depths and large soil volume
The two source area excavation alternatives
considered during the remedy selection process
(removal of soil within the Surficial Aquifer or
removal oi'soil to the Hawthorn Group middle
clay unit) would present significant challenges
due to the excavation depths and the large
amounts of soil that would be removed. The
Surficial Aquifer soil removal would require
digging to an approximate depth of 25 feet
below ground and removing approximately
280,000 cubic yards (420.000 tons) of soil. The
Hawthorn Group middle clay soil is deeper and
removal would require digging to an
approximate depth of 65 feet below ground and
removing approximately 1,800.000 cubic yards
(2,700,000 tons) of soil Excavating soil to these
depths would require shoring to keep the
Koppers Superfund Site
Community Involvement Plan
Page 1-3
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
LEGEND
SITE BOUNDARY
Bill ROAR
e UOMTCtlMG WELL
SOURCE AREA
» EXISTING BUILDING
STRUCTURE
ACTIVE EXTRACTION
. WELL AND
ASSOCIATED PIPING
CUE-PASS TRENCH
. AND ASSOCIATED
PIPING
: ,--, CHEMOX DEUVERY
• WELL
VERTICAL BARRIER
nREGRAOE/COVEH
AREA
CONSOLIDATION
AREA
NEW PIPINC
934 \SSS INJECTION
POINTS
4677 ISSS AUGER
POINTS
UPPER FLORIDAN
V AOUiFER GW
DrrRAeiio-j WELL
CHEMOX INJECTION
POINTS
350
roo
SCALE IN-EET
Figure 2.
On-Stte Preremed Remedy Plan View
Cabot Carbon/KoppeFs Superfund Site, Gainesville, FL-rida
Koppers Superfimd Site
Community Involvement Plan
Page 1-4
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
Table 1: Preferred Remedial Alternative Summary
Establishment of an on-site soil consolidation area that includes
c A single, continuous vertical barrier wall (approximately 65 feet deep)
encircling all four source areas from land-surface to the Hawthorn
Group middle day,
c Establishment of a bw-permeaMity cap "cover over the consolidation
area in protect against rain infiltration and contamination migration.
b place (in-situ) solidification and stabilization (TSS.S) of contamination
in the upper Hauthorn Crroup zone at all four same areas.
h-situbicgeochemical stabilization (ISBSj of'DXAPI. in the vadose-sme
(:he unsaturated znne above the water table) aid in the Surficial Aquifer
(less than 25 feet below ground surface} at all four source areas (tough
injection of oxidizing and stabilizing chemicals into the ground surface.
This treatment is subject lo acceptable performance demonstration during
pilo: tests or treatabife studies). Pilot tests Ireatability studies are tests
conducted with contaminated Site materials and stabilisers tc determine, if
cleanup goals will x .UK.
li-situ injection of oxidizing chemicals or 1SBS treatment in the Lower
Hawthorn Group at all four source areas, and along the eastern propeny
hound ai)'.
Excavation of soil posing a Icachabilny concern outside of the
consolidation area; placement of excavated soil in soil consolidation area,
Surface grading and cap covers on approximately S3 of 86 acres on the
Site property.
Installation of storm water controls and improvements 'e.g., retention'
detention pond).
Continued operation of the northern perimeter wells of the Surficial
Aquifer extraction and treatment system (outside of the consolidation
area) until cleanup goals are attained
Continual operation cftht horizontal collection drains of the SurJiciai
Aquifer extraction and treatment system as needed to contain potential
migration of ground water contamination (hydraulic control).
Expansion of the Surfkial Aquifer and Hawthorn Group monitoring
network.
hsfrtutional controls sucli as. deed restrictions to prevent future digging
thai would result in contact with contaminated media.
UFA Gfouittk'atff
• 'lydraulie containment of contaminated groundii'ater through eKtraetion
and treatment in areas where chemicals of concern (COCs) exceed
cleanup goals.
* Construction of additional extraction wells for the network, as necessaty.
* Monitored natural attenuation (MNA) in areas where concentrations of
COCs do not exceed cleanup goals (subject to demonstrarion of active
natural attenuation processes},
Off-Site Media
For soil contamination, a range of options are proposed for use on individual
sub parcels with the consent of private property owners including:
• Excavation and removal of impacted soil that exceeds cleanup goals teed
on present use of the land. Excavated soil will be transported and placed
within consolidation area on-site.
* Engineered controls that prevent contact with impacted soil containing
contamination that exceeds cleanjp goals based on present use of Jit land
use,
• Institutional controls to protect accessibility and use of lad •'properties.
Far surface water and sediment in Hogtcwn and Springstead Creeks, proposed
remedies include:
' On-site detention basin to mitigate on-going impasts to surface water
and sediment.
• Excavation and removal of impacted sediment in excess of levels
shown to likely cause an adverse effect when ia direct contact
(probable effects eoneaUialBn), lixeavaled soil will be placed a trie
consolidation area on-site,
* Monitored natural recovery of remaining impacted sediment until
concentrations reach threshold dfats concentrations (contaminant
concentrations above these levels could adversely effect a plant or
animal) or background levels.
Koppers Superfund Site
Community Involvement Plan
Page 1-5
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
excavation walls from falling in on workers, and
dewatering to remove groundwater that would
flow into the excavation area during excavation.
Ground water collected from the excavation area
would require treatment and disposal.
Construction of a staging/temporary storage
area may be required. Excavated soil would
require management as listed hazardous waste.
All of these challenges, in turn, result in short-
term health and safety risks to remedial workers
and the nearby community and significant
additional costs to the remedial effort.
2. Off-Site disposal challenges
Finding one or more disposal facilities that will
accept the large quantities of contaminated soil
would present a challenge. Land Disposal
Restriction (LDR) and Best Demonstrated
Available Technology (RDAT) rules
establishing treatment standards for land
disposal may require that contaminated soils
from the Site be sent to one of the lew
hazardous waste incinerators that accept wood-
treatment listed waste. It may also be necessary
to treat soils on-site prior It) oil-Site disposal.
Transporting the contaminated soils to an olT-
Site facility would require either about 15,000
(Surfieial Aquifer excavation) or 95.000
(Hawthorn Group middle clay excavation) truck
loads. More than 100 dump truck loads per day
of contaminated soil could he driven through the
areas surrounding the Site resulting in
significant transport-related safety and
environmental risks, as well as a significant
nuisance to the surrounding areas for over 2.5
years.
3, On-site treat ma it challenges
If the material is treated on-sile (by any method)
and returned to the excavation, the risk
reduction and volume treated is very' similar to
the in-situ treatment options, but with
substantially greater short-term risk, engineering
challenges, effort, time, and cost.
4. On-site construction iff above ground
landfill challenges
If the excavated soil is placed in an on-site
constructed landfill instead of being relumed to
the excavation or transported off-Site, the
resulting mound would be much larger than the
mound considered for the gently sloped
consolidation area. This would have serious
technical and permitting challenges, would limit
redevelopment opportunities, and would not be
a welcome sight for the community.
5. Risk feduction not significantly different
nith excavation
Actual long-term human health and
environmental risk reduction resulting from
source area excavation would not be
significantly different than in-situ treatment.
Short-term risks would be significantly higher
for soil excavation Soil removal will not
significantly reduce groundwater concentrations
at potential receptors, including the Murpliree
Well Field. A long-term groundwater remedy
would still be required. There is also a risk that
residual DNAPL will move through the
groundwater during excavation activities.
Why consolidate excavated soils on-
site?
Because of" the issues described above,
containing soils on-site is the optimal solution
for the community's needs. The soil
consolidation area will be designed to contain
the soil contamination and prevent human
contact and migration in groundwater off-Site.
"Die soil consolidation area is conceptually
shown on Figure 2 and Figure 3.
The most contaminated soil (principal threat
waste [PTW]) will be treated within the
consolidation area. There will be a gentle slope
on the containment area to prevent surface water
from accumulating. Other storm water
management controls such as rerouting and
detention basins will be used to reduce the
likelihood of surface water contact with
potentially contaminated soil.
Koppers Superfimd Site
Community Involvement Plan
Page 1-6
May 2011
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Appendix I
Proposed Plan Follow-tlp Preferred Remedy Fact Sheet, September 2010
(Continued)
SOIL CONSOLIDATION AREA
i=er
NOT TO SCALE
NOTE:
ELEVATIONS ARE APPROXIMATE
Figure 3.
On-Site Preferred Alternative
Cabot Catbon^Koppers Supeflund Site, Gainesville Florida
Koppers Superfimd Site
Community Involvement Plan
Page 1-7
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
Is the soil consolidation area in violation
of Florida laws?
The soil consolidation area being created oil-site
at ihc Koppcrs property is not considered a
landfill that is has to meet land disposal
restrictions (LDRs). The soil will be
consolidated within an Area of Contamination
(AOC). The National Contingency Plan (NCP)
policy (55 FR 8758-8760) allows EPA to
designate an AOC an an existing area of
continuous contamination of varying amounts
and types, LDRs will not apply il material is
moved within an AOC, treated in place, or
consolidated within an AOC. Establishment of
an AOC facilitates remediation of contaminated
sites.
How will groundwater be protected?
Given that digging up all the soil in source areas
is impracticable and ineffective as detailed
above, containment of source area materials is
required for protection of groundwater. Source
area materials within the on-site soil
consolidation area will be contained (Figure 3).
PTW within the area will be treated by in-situ
methods and a robust containment system will
be put in place to prevent migration away from
the area. This strategy has been used
successfully at many other Superiund Sites. At
the Koppers Site, tlie contaminants will be
contained by the following methods:
1. Continuous vertical barrier wall
The entire consolidation area will be surrounded
by a continuous vertical subsurface barrier wall
constructed of a cement/bentonite slimy (Figure
3). Slurry walls often are used in environmental
remediation where contaminants that move
through groundvvaler may pose a potential threat
to a source of drinking water. They have been
used for decades as long-term solutions for
controlling seepage. Slum walls are typically
constructed of a soil, bentonite (clay), and water
mixture. However, a cement,'bentonite (such as
proposed at the Koppers Site) or other mixture
may be used for greater structural strength and
lo reduce degradation due to chemical
interactions. The barrier wall will be joined to
the top of the low permeability Hawthorn Group
middle clay unit {approximately 65 feet below
ground) Because the Hawthorn Group middle
clay layer docs not readily transmit water due to
its low permeability and the surface cover/cap
minimizes water from entering below the
surface, the vertical barrier wall creates a
subsurface containment area designed to
completely surround the contaminated soil and
groundwater in the surtlcial aquifer and I ;pper
Hawthorn sediments.
2. Low permeability Hawthorn middle clay
The Hawthorn Group middle clay unit transmits
very little groundwater as evidenced by pressure
measurements above and below this clay unit.
Working together, the vertical barrier wall and
the middle clay layer will limit downward
movement of contamination.
3. Lmv permeability surface cover/cap
ITie consolidation area will be covered with a
low-permeability cap/cover that is a minimum
of two feet thick and is constructed of clean
material. This cover/cap will be gently sloped
to promote storm water runoff and prevent
pooling. Hie intent of the cap will be to prevent
surface exposure to contaminated soil and limit
rainfall from entering the subsurface within the
consolidation area.
4. ln-Sitii Treatment
In-situ treatment of contaminated soil and
groundwater within the consolidation area
above the Hawthorn Group middle clay will
reduce volume and toxicity of contaminated
media and the potential for contaminant
migration.
5. Groundwater monitoring
Ilie EPA will monitor the groundwater in and
around the soil consolidation area. Although it
is unlikely, if increasing contamination
concentrations are observed outside of the
containment area, additional remedial actions
may be evaluated for implementation.
6. (iroundwater pump and treat system
Groundwater pump and treat systems will be
operated in the Surficial Aquifer and the UFA to
prevent contaminated on-site groundwaler from
moving off-Site.
Koppers Superfimd Site
Community Involvement Plan
Page 1-8
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
7. Soils removal
Soils outside the containment area with
concentrations high enough to pose a
concern due to leaching to groundwater will
be removed and placed within the
containment/consolidation area. During the
remedial design additional teachability studies
will he done to assess areas for soil removal.
How will cleanup goals be met for soil
outside of the soil consolidation area?
The green area on Figure 2 outside of the
consolidation area that will be regarded and a
clean soil cover of at least two feet thick will be
placed over almost the entire property. 1 he
process of Site grading which is necessary for
Site reuse preparation and stomiwaler
management will result in the excavation of
impacted surface soil This soil will be moved
to the consolidation area (blue area) of Figure 2.
The clean cover with institutional controls will
prevent contact with soils that may contain a
low level of contaminants.
Why aren't residential cleanup goals
selected for on-site soil?
EPA is required to look at reasonably
anticipated future land uses in determining what
cleanup criteria to apply at a Superfund Site.
liP A has determined that unrestricted residential
use is not a likely or practical future land use for
the Site. However, a remedy that in effect
meets Florida residential default cleanup
standards has been selected. The remedy calls
for clean soil to be placed over almost the entire
Site. FPA has made its reasonably anticipated
land use determination based on several factors
including property owner Reazer East's planned
retention of Site ownership and its indicated
future use of the Site as commercial.
recreational or raised use with a residential
component. Therefore, the EPA has determined
that the reasonably anticipated future land use of
the Koppers portion of the Site is likely to be
commercial, recreational or mixed-use with a
residential component.
What institutional controls will be
applied at the Site?
Institutional controls will be applied at the Site
to prevent exposure to subsurface soil and
groundwater contamination. The institutional
controls are controlled by local authorities and
will become part of the property deed. They
will prevent digging without formal plans to
mitigate exposure to contaminants (via permits,
etc.).
Will in-situ stabilization be effective?
ln-situ stsibilization/solidificalion (1SS) is
proposed to treat source area contamination in
the upper Hawthorn Group. In-situ
biogeochemical stabilization (1SBS) is proposed
to treat source area residual DNAPL in the
vadose-zone (above the water table) and
Surficial Aquifer. In-situ chemical oxidation or
1SBS is proposed to treat contamination in the
lower Hawthorn Group at source areas and
along the eastern property boundary as an
additional treatment method for groundwater
migrating oil-Site.
EPA lias demonstrated the effectiveness of in-
situ stabilization at other wood treatment sites
with soil contaminated by DNAPL and mixed
wastes. During the remedial design of this
remedy, treatability studies will be conducted to
determine the appropriate type and quantity of
in-sitn stabilizer that will bind the contaminated
soil and meet requirements for effective
stabilization. Treatability testing will use
contaminated soils from the site to determine
the type and amount of stabilizer needed.
A pilot test of 1SBS has been conducted at the
Site,
Off-Site Creek Cleanup
Community concerns and details regarding off-
Site cleanup of nearby creeks are addressed
below. Off-site soil cleanup activities are
detailed in a separate fact sheet.
Koppers Superfund Site
Community Involvement Plan
Page 1-9
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
How are Hogtown and Springstead
Creeks being addressed?
The selected remedy address citizen concerns
with the creeks in two distinct ways, First, to
address previous, contamination of the sediments
in each creek, sediments that have contaminant
concentrations associated with cither former
Cabot Carbon or Koppers that exceed the
threshold effects concentrations (i.e.
contaminant concentrations in excess of levels
that would adversely effect animal life) are
required to he excavated and replaced with
clean fill material. Assessment of creek
sediments is ongoing. To address possible
future impacts on sediments, the former
Koppers facility is required to construct and
operate a detention/retention pond(s)to capture
storm water from the former Koppers Site prior
to allowing it to be discharged to the tributary' to
Springstead Creek. The detention.retention
pond(s) will be designed, including placement
during the remedial design of the on-site
remedy.
Although future migration of contaminated soils
due to storm water flow is highly unlikely due
to the implementation of Site surface covers and
consolidation of contaminated materials beneath
a low-peraieability cover'cap. storm water
capture will allow potentially contaminated
sediment to settle so that it will not be released
to the creeks.
Other Community Concerns
General community concerns not covered in the
previous sections of this fact sheet relating to
the Koppers remedial action are addressed
below.
Why was the FS not certified by a
professional engineer?
'ITie NCP regulations found at 40 Code of
Federal Regulations (CFR) Part 300. contains
the EPA regulations for implementing
C'KRCEA, as well as governance on documents
to he submitted to the agency. Per EPA FS
guidance, the FS is a conceptual document that
supports the design of selected remedies. The
NCP requires certification of engineering design
documents; therefore, design documents for the
Koppers Site generated during the remedial
design phase of the project, will be signed and
sealed by a professional engineer registered in
the State of Florida. The remedial design of the
selected remedy will occur after the Record of
Decision (ROD) is signed.
When will the Community Involvement
Plan be updated?
EPA developed the Community Involvement
Plan (CIP) to serve as a framework for
community involvement and outreach efforts
associated with the Cabot Carbon'Koppers
Superfund Site. The CIP addresses the
relationship between the Site, the community.
and EPA. provides a background of the
community; presents RPA's community
involvement program; and provides a listing of
resources. The goals of the CIP are to inform
the public of planned and ongoing site activities;
maintain open communication about site
remediation: ensure that former concents are
acknowledged and addressed; provide interested
parties with useful information; provide citizens
with opportunities to comment on and be
involved in technical decisions; and encourage
and assist local citizens in providing input to
agency decisions that will have long-term
effects on the community. Information
discussed during community interviews is
essential in developing the CIP. Hie CIP update
is expected lo be complete by late September
2010.
How will EPA evaluate the cleanup
process and what happens if it is
unsuccessful?
EPA will evaluate the progress of the cleanup
through confirmation sampling of soils and
sediments once a remedy has been
implemented. Ground water sampling will
continue after remedy implementation has taken
place. Groundwatcr data will be evaluated to
ensure that contaminant levels are reduced over
lime until target cleanup levels are met. Surface
water discharges will also he sampled and
analyzed on a quarterly basis to ensure that
permitted levels are met. In addition, EPA is
required to evaluate remedial action
effectiveness once every five vears in a F-ive-
Koppers Superfund Site
Community Involvement Plan
Page I-10
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
Year review to determine if the remedy is
functioning as intended. If the remedy does not
function as intended, EPA will update the
remedy to include additional measures so that
tile updated remedy is effective.
What is being done to ensure no
contamination has been missed at the
Site?
A work plan is being developed for the remedial
design phase of the project to identify if there
are possible buried drums or other primary
source areas on the Site. In addition, soil,
groundwater, and sediment sampling and
analyses will continue as the footprint for
installation of all the remedial technologies is
relined. After additional sampling and analyses
occur and the remedial action is implemented,
the proposed oil-site actions will ensure
exposure at the surface has been mitigated.
How are vapor intrusion possibilities
being addressed?
The Site groundwater contaminant plume does
not consist of significant concentrations of
highly volatile components such as solvents or
13'1 EX compounds, The primary concern in Site
groundwater is low con central ions of
naphthalene which are only partially volatile.
Vapor intrusion is unlikely at wood-treatment
sites, and is not anticipated to create a haxard at
the Koppers Site.
What studies are being conducted to
assess Site-related human health
concerns?
Human health risks due to exposure to on-site
contaminants have been assessed. Human
health risk assessments typically look at the
types of activities thai may expose people to
Site contaminants. In general. Site media
concentrations arc compared to various
riskbenchmarks to determine whether the type
of contaminant at its concentration present a
risk. Contaminants thai present a significant
risk are included as Site chemicals of concern
(COCs). COCs were listed in the Proposed
Plan.
EPA provides information to the community
regarding Site cleanup through fact sheets,
public meetings, local Site information
repository, and the Administrative Record file.
Copies of data and reports generated during Site
investigations for use in the remedy selection
process arc located in the Administrative
Record file. 'Ilns fact sheet will become part of
the Administrative Record file for the cleanup
decision for the Cabot Carbon /Koppers
Superfund Site, 'llie public may review this file
at the Alachua County Library.
EPA will be providing an additional opportunity
for the community to address any remaining
questions they may have about Site cleanup
during an availability session that will be held
from 6:00 PM until 9:00 PM on October 6.
2010, al me Eastside Community Center. 2841
East University Avenue, Gainesville, Florida
32601.
Koppers Superfund Site
Community Involvement Plan
Page I-11
May 2011
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Appendix I
Proposed Plan Follow-Up Preferred Remedy Fact Sheet, September 2010
(Continued)
Availability Session Mailing List
An availability session for the Cabot Carbon. Anyone wishing to be placed on the mailing list
Koppers Superfitnd Site will be held from 6:00 for this Site should send his/her request to Ms.
PM until 9:00 PM on October 6, 2010, al the LaTonya Spencer, EPA Community
Eastside Community Center, 2841 East Involvement Coordinator, al the above address.
University Avenue, Gainesville, Florida 32601. You may also call Ms. Spencer with your
request at (800) 435-9234 or (404) 562-8463
Information Repositories
Information concerning the Cabot Carbon'
Koppers Superfiind Site may be found at the
following location:
Alachua County Library
401 E. University Ave.
Gainesville, FL 32601
(352) 334-3860
www.aclib.us/locations/headquarters
Koppers Superfiind Site
Community Involvement Plan Page 1-12 May 2011
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Appendix J
Glossary
Administrative Order on Consent (Administrative Order):
A legal agreement between the United States Environmental Protection Agency (EPA)
and potentially responsible parties (PRPs) whereby PRPs agree to conduct or pay the cost
of a site investigation and/or cleanup. In contrast to a consent decree, an administrative
order by consent does not need to be approved by a judge.
Administrative Record File:
A file that is maintained for the public and contains information used to make a decision
about a site under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). The file is available for public review, and a copy is usually
placed in the same location as the site information repository. A duplicate file is held at a
central location, such as the EPA Regional office.
Agency for Toxic Substances and Disease Registry (ATSDR):
Superfund created ATSDR within the federal Public Health Service to work with other
government agencies to initiate and implement a variety of health-related responsibilities.
ATSDR develops toxicological profiles, prepares site-specific health assessments,
establishes formal registries of persons exposed to hazardous substances, develops and
disseminates health education information, establishes and maintains literature
inventories on hazardous substances, helps prepare health and safety programs for
workers at Superfund sites and workers responding to emergency releases, and provides
health-related support in public health emergencies.
Availability Session:
An "open house" event hosted by EPA to meet informally with citizens about site
activities.
Cleanup:
Actions taken to deal with a release or threatened release of hazardous substances that
could affect public health or the environment. The term is often used broadly to describe
various response actions or phases of remedial responses, such as the Remedial
Investigation/Feasibility Study (RI/FS).
Cleanup Remedy:
A prescribed technical approach to reducing the concentrations of contaminants at a site.
EPA selects a cleanup remedy from alternatives identified in the feasibility study after
applying a set of balancing criteria and considering public comments.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
Federal Law, commonly known as Superfund, passed in 1980 and modified in 1986 by
the Superfund Amendments and Reauthorization Act (SARA) to investigate and cleanup
abandoned or uncontrolled hazardous waste sites (CERCLA is commonly known as
Superfund, because the Act created a special tax that goes into a Trust fund). EPA either
Koppers Superfund Site
Community Involvement Plan Page J-1 May 2011
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Appendix J
Glossary (Continued)
pays for the site cleanup when the responsible parties cannot be located or are unwilling
or unable to perform the remedial actions, or takes legal action to force responsible
parties to cleanup the site or reimburse EPA for the cost of the cleanup.
Community Involvement Plan (CIP):
The goals of the CIP are to inform the public of planned and ongoing site activities;
maintain open communication about site remediation; ensure concerns are acknowledged
and addressed; provide interested parties with useful information; provide citizens with
opportunities to comment on and be involved in technical decisions; and encourage and
assist local citizens in providing input to agency decisions that will have long-term
effects on their community
Feasibility Study (FS):
The second part of a two-part study called a remedial investigation/feasibility study. The
feasibility study involves identifying and evaluating the most appropriate technical
approaches to addressing contamination problems at a site. Alternatives are evaluated for
their effectiveness in protecting human health and the environment.
Florida Department of Environmental Protection (FDEP):
An agency in Florida's government charged with most functions relating to
environmental quality in the state.
Groundwater:
Water found underground that fills pores between materials such as sand, soil, or gravel.
In aquifers, groundwater often occurs in quantities where it can be used for drinking
water, irrigation, and other purposes.
Hazard Ranking System (HRS):
A numerical screening system used by EPA to evaluate the relative potential risks to
public health and the environment from releases or threatened releases of hazardous
substances from contaminated sites. Data from preliminary site investigations is used to
develop a site score from 0 to 100 indicating the potential for substances released in
groundwater, air, surface water, or soil to affect people on or near the site. The HRS
ranking is the principal factor used to determine if a site qualifies for the National
Priorities List.
Health Consultation:
A review of available data by the ATSDR at EPA's request to determine if existing levels
of contaminants and conditions at a site are creating a public health hazard that requires
immediate action.
Information Repository:
The information repository is usually located in a public building that is convenient for
local residents, such as a public school, city hall, or library, and contains current
information, technical reports, reference documents, and other information regarding a
Koppers Superfund Site
Community Involvement Plan PageJ-2 May 2011
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Appendix J
Glossary (Continued)
Superfund site. As the site proceeds through the remedial process, the file at the
information repository is contractually updated.
National Priorities List (NPL):
A list generated by EPA depicting the uncontrolled or abandoned hazardous waste sites
that are priorities for long-term remedial investigation (RI) and response. The list is
based primarily on the score a site receives on the Hazard Ranking System. A non-
federal site must be on the NPL to receive money from the Trust Fund for Remedial
Action. Federal properties listed on the NPL do not receive money from the Trust Fund,
but EPA takes a more formal role in the cleanup process. EPA is required to update the
NPL at least once a year.
Potentially Responsible Party (PRP):
An individual, company, or group of companies that may have contributed to the
hazardous conditions at a site. These parties may be held liable for costs of the remedial
activities by EPA through CERCLA laws.
Preliminary Assessment:
The process of collecting and reviewing available information about a known or
suspected hazardous waste site or release status.
Proposed Plan:
A public participation requirement of CERCLA in which EPA and/or the PRP summarize
for the public the preferred cleanup strategy, rationale for the preference, and alternatives
presented in the detailed analysis of the RI/FS. The proposed plan may be prepared as a
fact sheet or a separate document. In either case, it must actively solicit public review
and comment on all alternatives under consideration.
Public Comment Period:
The time in which the public can review and comment on various documents. A 30-day
minimum comment period is held to allow the community to review and comment on the
document.
Record of Decision (ROD):
A ROD provides the justification for the cleanup remedial action (treatment) chosen at a
Superfund site. It also contains site history, site description, site characteristics,
community participation, enforcement activities, past and present activities, contaminated
media, the contaminants present, scope and role of response action, and the remedy
selected for cleanup.
Remedial Action:
The actual construction or implementation phase that follows the remedial design of the
selected cleanup alternative at a CERCLA site.
Koppers Superfund Site
Community Involvement Plan PageJ-3 May 2011
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Appendix J
Glossary (Continued)
Remedial Design:
An engineering phase that follows the ROD when technical drawings and specifications
are developed for subsequent remedial action at a CERCLA site.
Remedial Investigation (RI):
A study designed to collect the data necessary to determine the nature and extent of
contamination at a site.
Responsiveness Summary:
A summary of oral and written comments received by EPA during a public comment
period on key site-related documents, with EPA's responses to those comments. The
responsiveness summary highlights community concerns to be taken into account by
EPA in making decisions on a site and is a key part of the ROD.
Risk Assessment:
An evaluation of the likelihood of exposure and potential magnitude of future health or
environmental effects that could occur if no cleanup action is taken on a site. Risk
assessment may include both qualitative (non-numerical) evaluation and quantitative
(numerical) calculations based on specific assumptions about long-term exposure risks.
Ecological risk assessment applies to animals, fish, vegetation, and other environmental
receptors. Human health risk assessment estimates the potential effects on people. Risk
assessment results are used to identify site cleanup requirements.
Superfund:
The trust fund established under CERCLA to pay for cleanup of abandoned hazardous
waste sites if PRPs cannot be identified. Superfund is the common name for CERCLA
and is often used as an adjective for hazardous waste sites and the investigation and
cleanup process directed by EPA.
Superfund Amendments and Reauthorization Act of 1986 (SARA):
SARA established standards for cleanup activities and stipulates the conditions for offsite
disposal of wastes. The amendments also clarified many public participation questions
and made federal facilities accountable under the statute.
Technical Assistance Grant (TAG)
The purpose of the Technical Assistance Grant is to increase the level of understanding
and participation in the Superfund process among community members and provide
independent technical review of Site documents. As part of the Administrative Order by
Consent, a grant in the amount of $50,000 is awarded to a community group (that is
directly affected by the Superfund Site) that is responsible for hiring and managing a
Technical Advisor, to assist the affected community. The community group is also
responsible for disseminating information to additional stakeholders or other affected
communities.
Koppers Superfund Site
Community Involvement Plan PageJ-4 May 2011
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Appendix J
Glossary (Continued)
United States Environmental Protection Agency (EPA):
Established in 1970 to bring together parts of various government agencies involved with the
control of pollution.
Koppers Superfund Site
Community Involvement Plan PageJ-5 May 2011
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Appendix L
Summary of Public Involvement and Outreach
Appendix K
Demographic Information
People Quick Facts Alachua County Florida
Population, 2009 estimate1
Population, percent change, April 1 , 2000 to July 1 , 2009
Population estimates base (April 1) 2000
Persons under 5 years old, percent, 2008
Persons under 1 8 years old, percent, 2008
Persons 65 years old and over, percent, 2008
Female persons, percent, 2008
White persons, percent, 2008
Black persons, percent, 2008
American Indian and Alaska Native persons, percent, 2008
Asian persons, percent, 2008
Native Hawaiian and Other Pacific Islander, percent, 2008
Persons reporting two or more races, percent, 2008
Persons of Hispanic or Latino origin, percent, 2008
White persons not Hispanic, percent, 2008
243,574
11.8%
217,955
5.7%
18.7%
10.5%
50.7%
73.7%
19.5%
0.3%
4.6%
0.0%
1.8%
7.4%
66.9%
18,537,969
16.0%
15,982,839
6.2%
21.8%
17.4%
50.9%
79.8%
15.9%
0.5%
2.3%
0.1%
1.4%
21.0%
60.3%
1 According to the University of Florida Bureau of Economic and Business Research, the 2009 population for
Alachua County is estimated to be 256,232 with approximately 107,260 residents living within unincorporated
areas.
Koppers Siiperfimd Site
Community Involvement Plan
PageL-1
May 2011
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Appendix L
Summary of Public Involvement and Outreach
Alachua
Business QuickFacts County Florida
Private nonfarm establishments, 2007
Private nonfarm employment, 2007
Private nonfarm employment, percent change 2000-2007
Non-employer establishments, 2007
Total number of firms, 2002
Black-owned firms, percent, 2002
American Indian and Alaska Native owned firms, percent, 2002
Asian-owned firms, percent, 2002
Native Hawaiian and Other Pacific Islander owned firms, percent,
2002
Hispanic-owned firms, percent, 2002
Women-owned firms, percent, 2002
5,991
87,130
7.0%
15,465
17,163
5.0%
0.0%
2.5%
0.0%
5.6%
29.5%
523,461
7,425,331
19.4%
1,618,119
1,539,207
6.6%
0.6%
2.7%
0.1%
17.3%
28.4%
Koppers Superfimd Site
Community Involvement Plan
Page L-2
May 2011
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Appendix L
Summary of Public Involvement and Outreach
Date
Event
Subject
8/2007-
5/2010
Collaborative
FS
FDEP, Beazer East, EPA begin a series of 6 face-to-face
meetings preparing Feasbility Study documents for review and
comment by Gainesville Local Implementation Team (LIT) in
iterative stakeholder process
ueiaiive suuvenuiuci pioecss
EPA representatives participate in Koppers Site quarterly
meeting with interested community who participate in plant
11/17/2007
Koppers
Citizen
Advisory
Meeting
meeting
meetings
4/2008
EPA Awards
ACEPD Grant
EPA Region 4 awards Alachua County EPD a $108,000 grant to
study creek sediments and stormwater runoff at the Koppers
facility and former Cabot Carbon lagoons
5/1/2008
Joint
Gainesville
City/Alachua
County
Commission
Meeting
Provide updates related to Site remedial investigations/interim
remedial measures, redevelopment possibilities, soil cleanup
levels. Took questions from Commissioners and general public
See it online at the City of Gainesville website, Commission
Meetings Online
3/9/2009
Gainesville
City
Commission
Special
Meeting
Provide information related to land use and soil cleanup
standards at Superfund Sites. Took questions/received feedback
from Commissioners and general public
See it online at the City of Gainesville website, Commission
Meetings Online
6/11/2009
EPA Public
Availability
Session
EPA, FDOH, Alachua County DOH, and Beazer East
representatives provide face-to-face information to members of
the public to discuss soil sampling data results obtained nearby
the former Koppers plant
7/2009
Koppers Site
Video
Community Involvement Coordinator and RPM provide a guided
tour of the operating Koppers Site and discuss specific operations
and cleanup at the Site. A Bob Safay Production.
See it at:
http: //www. epa.gov/region4/waste/np 1/nplfln/koppers jvideo .html
8/31/2009
Public Release
of Draft
Collaborative
Feasibility
Study
Release of Draft Feasibility Study to public, document results of
6 face-to-face meetings with FDEP, Beazer East, and EPA with
input from the Local Implementation Team (LIT)
11/23/2009
Meeting at
EPA Region 4
with LIT,
Gainesville
Face-to-Face Meeting to discuss LIT concerns with draft FS with
EPA and FDEP representatives
Koppers Superfund Site
Community Involvement Plan
Page L-l
May 2011
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Appendix L
Summary of Public Involvement and Outreach
1/27/2010
1/6/2010
3/26/2010
4/29/2010
6/1/2010
6/14/2010
6/15/2010
8/1-3/2010
8/5/2010
8/1 61-
9/15/2010
8/17/2010
9/23/2010
City/Alachua
County Elected
Officials
Gainesville
Commission
Meeting
Administrator
Meiburg Meets
With Mayor
Hanrahan
Reuse Public
Meetings
Gainesville
City
Commission
Meeting
Technical
Assistance
Grant Award
Reuse Public
Meeting
Koppers Site
Tour
Community
Interviews
Proposed Plan
Meeting
Draft
Community
Involvement
Plan Public
Notice
Koppers Site
Tour
Meeting with
LIT in
Tallahassee to
Discuss EPA
EPA personnel address questions related to December 2009
Koppers Site shutdown
Senior Management meeting with Mayor to discuss City
concerns and path forward for proposed plan
Pursuant to public request, EPA contractor E conducts three
meetings without presence of federal, state, local, and city
personnel to engage in discussion of possible site reuses.
EPA personnel provide updates on several interim remedial
measure development and takes feedback/questions from the
public See it online at the City of Gainesville website,
Commission Meetings Online
EPA awards Protect Gainesville Citizens technical assistance
grant
EPA reuse contractor E" meet with members of the public to
discuss their ideas related to possible former Koppers Site reuse
EPA and Beazer East representatives provide Site tour to
interested public and take feedback on possible drums buried
onsite eyewitnesses. Remedial design workplan for further
submitted based on testimonials received
Community Interviews in preparation for Community
Involvement Plan update
EPA representatives present Koppers proposed plan and take
public comments/answer questions for 3 hours
Updated Community Involvement Plan public-noticed in
Gainesville Sun
EPA an Beazer East representatives provide a Site tour to discuss
Site demolition efforts to remove Site structures, implement an
interim remedial measures for stormwater management and dust
control measures
EPA, FDEP, and Beazer East representatives meet with LIT
members to discuss EPA's proposed plan and local technical
concerns
Koppers Superfund Site
Community Involvement Plan
Page L-2
May 2011
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Appendix L
Summary of Public Involvement and Outreach
10/6/2010
11/3/2010
11/4/2010
11/16/2010
12/2/2010
1/12/2011
2/2/201 1
2/2/2011
2/15/2011
3/8/2011
3/18/2011
Proposed Plan
Elements
EPA Public
Availability
Session
EPA Five- Year
Review
Interviews
Five- Year
Review Site
Walk and
Gainesville
Stakeholder
Five- Year
Interviews
FDOH/EPA
Indoor Dust
Sampling
Workgroup
FDOH/EPA
Indoor Dust
Sampling
Workgroup
FDOH/EPA
Indoor Dust
Sampling
Workgroup
RA Conference
Call with City
of Gainesville
Alachua
County Elected
Officials
ROD Issued
Gainesville
Stakeholder
Conference
Call
PGC Technical
Advisor
FDOH/EPA
Indoor Dust
EPA, FDOH, FDEP, Alachua County DOH, and Beazer East
representatives provide information related to contents of EPA
proposed plan and answer specific questions that members of the
public have related to Koppers
EPA personnel interviewed Mayor Lowe and four City
Commissioners for the 201 1 Five-Year review
Interviewed Gainesville stakeholder representatives from the
GRU, ACEPD, the City of Gainesville
Public interest groups the Stephen Foster Neighborhood
Association, the Stephen Foster Neighborhood Protection Group,
BANCCA, and the Protect Gainesville Citizens TAG recipient,
Seven individual residents that live nearby the former Koppers
Site
Community members, FDEP, FDOH, ACEPD, CDC
representatives begin discussions of possible approaches to
sampling indoor dust for presence of possible Site-related
contaminants
Community members, FDEP, FDOH, ACEPD, CDC
representatives continue discussions of possible approaches to
sampling indoor dust for presence of possible Site-related
contaminants
Community members, FDEP, FDOH, ACEPD, CDC
representatives continue discussions of possible approaches to
sampling indoor dust for presence of possible Site-related
contaminants
Regional Administrator and technical staff provide a briefing to
City of Gainesville, Alachua County elected officials and
technical representatives, Protect Gainesville Citizens TAG
technical advisor on ROD issuance, next steps.
Press release and ROD summary issued on website.
ACEPD, FDEP, City of Gainesville, GRU, PRP Beazer East and
Cabot Carbon technical representatives discuss ROD contents,
next steps including consent decree negotiations.
Shared draft workplan documents for offsite soil sampling,
buried drum remedial investigation, and held conversations
related to Site cleanup efforts and PGC concerns
Community members, FDEP, FDOH, ACEPD, CDC
representatives continue discussions of possible approaches to
Koppers Superfund Site
Community Involvement Plan
Page L-3
May 2011
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Appendix L
Summary of Public Involvement and Outreach
Sampling
Workgroup
sampling indoor dust for presence of possible Site-related
contaminants
3/24/2011
Former
Koppers Site
Walk
Review stormwater improvements, completed site demolition
results and provide information on upcoming remedial actions.
4/8/2011
FDOH/EPA
Indoor Dust
Sampling
Workgroup
Community members, FDEP, FDOH, ACEPD, CDC
representatives continue discussions of possible approaches to
sampling indoor dust for presence of possible Site-related
contaminants
4/19/2011
Gainesville
Stakeholder
Conference
Call
ACEPD, FDEP, City of Gainesville, GRU, PRP Beazer East and
Cabot Carbon technical representatives discuss workplans for
offsite soil sampling plan, remedial design documents, and
buried drum remedial investigation.
4/29/2011
FDOH/EPA
Indoor Dust
Sampling
Workgroup
Community members, FDEP, FDOH, ACEPD, CDC
representatives continue discussions of possible approaches to
sampling indoor dust for presence of possible Site-related
contaminants
Remedial Action Milestones Since 2/2/2011 ROD Issuance
Date Item Description
4/14/2011
Special notice letter issued to
Beazer East
Issuance of special notice
letter to Beazer East
begins consent decree
negotiations for
conducting the
remedial
design/remedial action
for Koppers portion of
the Site
Completed 4/1/2011
Creek sediment removal
action
116 tons of contaminated
sediment were
removed and replaced
with clean sediment in
Hogtown and
Springstead Creeks
Koppers Superfund Site
Community Involvement Plan
Page L-4
May 2011
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